Regulatory Agencies Release Social Media Guidance for Financial Institutions

The Federal Financial Institutions Examination Council (FFIEC), composed of various financial regulatory agencies, issued guidance to help financial institutions with compliance and legal issues surrounding the use of social media. FFIEC suggests that financial institutions develop a social media risk management program that creates clear policies and procedures regarding the use of social media, and includes employee training, oversight for monitoring information posted to third-party sites, and internal audit procedures to ensure compliance with such policies. Areas to consider include: appropriate disclosures in social media advertisements, appropriate collection and security of data collected through the use of social media, making sure social media advertisements do not impermissibly target a demographic based on protected criteria, and that communications with clients through social platforms properly protect personal information. The guidelines can be found at Social Media: Consumer Compliance Risk Management Guidance. For more information, please contact Erich M. Paetsch.